ML19320A465

Forwards Summary Status of Reg Guides Reviewed by Mechanical Engineering Branch & Addl Discussion of Individual Reg Guides

ML19320A465
Person / Time
Site:	Midland
Issue date:	08/25/1977
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
4122, NUDOCS 8006180683
Download: ML19320A465 (9)

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Stephen H. Howell Vice President General Offices: 1945 West Parnell Road, Jackson, Michigan 49201

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~.:CHA!ICAL LICI.!2ERIi!G EVALUACIOJ OF EZGULAT03Y GUIL POSITIO.!S FILE: 0505 SZRIAL: 4122 Mr S A Varga's September 24, 1976 letter trcnstitted the !!EC Staff evcluation of the Consumers Pcuer Company position on Regulatorf Guides 1.20, 1.26, 1.29, 1.46, 1.k8, 1.67, and 1.72 relative to the a dland Plant. Subsequent to your review sone of our positions have changed or require additional clarification due to reinterpretation of Regulatorf G2Lde contents. Also, ve wish to advise you of cur int?nded action in thora areas where the Staff's pcsition is inter-preted to 'ce different from the Consuner's positicn. is a Su rarf Status of each Repulctorf Guide reviewed in the

echanical Engineering catecorf. Attcchtents 2 and 3 provide c.dditional dis-cussica of individual 2egulatorf Guides.

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The attac.hed ratcrial is for inferLation only cince IZC evaluation of the final

1dland Plc.nt Ze;;ulator/ Cuide pcsitions vill be per orned durin; review of the c

Final 3afety Analysis Eeport whica is scheduled for subnittal on September 1, 1977 L- -

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SIEi/jbg CC: CEMahaney, Lynchbur-THIS DOCUMENT CONTAINS 2

ELCastleberry, A POOR QUAUTY PAGES

SUMMARY

STATUS OF MECHANICAL REGULATORY GUIDES s

Regulatory Guide, Cocunent 1.20 NRC agrees with the Midland position 1.26 NRC agrees with the Midland position 1.29 NRC agrees with the Midland posit on d

1.46 See Attachment 2 1.48 See Attachment 3 1.67 NRC agrees with the *idland position 1.72 NRC agrees with the Midland position e

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techment 2 Regulatorv Guide 1.46

" Protection Against Pipe Whip Inside Contain-ment" - (May 1973)

The staff has accepted the Midland position as submitted,0ctober 10, 1975 and modified in discussions on November 18, 1975 and May 21, 1976.

Further, NRC approval of the criteria to be applied on the primary system, submitted by our letters of May 10, 1977 and June 8, 1977, has been provided by NRC letter, Steve A. Varga to S. H. Howell, dated June 20, 1977.

The clarifications to the criteria for the primary system recommended by this NRC letter have been added, and will appear in the FSAR.

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Attrchment 3 Y

1 Regulatory Guide 1.48

" Design Limits and Loading Combinations for Seismic Category I Fluid System Components" - (May 1973_)_

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The NRC staff accepted the Midland position on this guide except for the topics discussed below where the applicant's intended action is provided.

Note:

Numbering is in agreement with the NRC evaluation as contained in the Sentember 24, 1975 letter to CPCo.

1.

Seismic qualification by testing for vital anpurtenances of active pumps and valves purchased prior to July 1, 1975.

As a result of our October 14, 1976 meeting with the NRC staff, we understand the staff's desire is to have small critical appurtenances such as switches, etc, which do not lend themselves to analytical techniques, qualified by testing. Analytical qualification would be acceptable to the NRC for large appurtenances such as pump motors.

As stated in our response to Regulatory Guide 1.48, seismic qualifi-cation by test or analysis of balance of plant components purchased prior to July 1, 1975 was allowed.

The selection of methods to be employed was at the choice of the component designer. We have not completed our compilation of seismic qualification methods which were employed on active pumps and valves.

This information will be pre-

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sented in Section 3.9 of the FSAR.

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1,o 2 We do not intend to take any action toward requalification by testing of any equipment qualified by analysis until such time as the NRC has reviewed the qualification programs described in the FSAR and has found specific cases, if any exist, where the qualifi-cation is deemed unacceptable.

II.1 Combination of Seismic and Faulted loads The applicant understands from our meeting with the staff that the combination of seismic (SSE) loads with LOCA related faulted loads for the components of the reactor coolant pressure boundary in Bechtel's scope is the concern of the staff. Further, we understand that it was not the staff's intent to require combination of SSE loads with non-LOCA related faulted loads.

In response to the staff's dictate on load combinations, the stresses and loads associated with a loss of coolant accident will be combined, by the squars-root-of-the-sum-of-the-squares method, with stresses and loads from SSE for balance of plant ASME Class 1 pipe which is part of the reactor coolant system including that pipe extending to the second branch line isolation valve.

The resulting

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stresses will be summarized in Section 3 of the FSAR.

The associated stress level which will be met and against which this combination will be compared for the purpose of establishing the existance of additional margin will be as provided for faulted load conditions in Table 1, sheet 11 of the applicant's position.'

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However, the applicant will not accept this as a credible load combination which could actually occur and thus the ASME Class 1 stress reports for the Midland Plant balance of plant Class 1 pipe will not include this combination.

This margin is thus considered by the applicant to be an additional margin which is being provided to account for any possible additional credible loads which might bc identified in the future. Use of this margin will not be made without prior notification and dir ussion with the NRC.

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i 11.2 A&B Staff Exce?tions to IEEE344 1975 A review was conducted to identify any purchase orders issued after July 1, 1975, which fall under the scope of Regulatory Guide 1.48 and which also contain electrical compon nts to which IEEE-344 applies. This survey identified six purchase orders. These orders and the action taken to resolve the staffs comments on IEEE-344-1975 are indicated below.

(1 and 2) P.O. 7220-J-258 Motor Operated Control Valves It is required that the vendors demonstrate that the extended motor

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operator h'as a natural frequency greater than 33 cps.

These components are thus classified as rigid, and the NRC Comments A and B do not apply, therefore no action is required.

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(3) P.O. 7220-M-19 Emergency Diesel Fuel Oil Transfer Pump Qualification of this component will be accomplished by analysis and the equipment will be rigid.

Since this equipment will be rigid, the NRC Comments A and B are not applicable to this purchase order.,'

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'~ Attichm:nt 3 Pcga 4 (4) P.O. 7220-M -18 Emergency Diesels and Auxiliaries The auxilary fluid systems of the emergency diesels fall under the scope of Regulatcry Guide 1.48.

The NRC comments on IEEE-344-1975 were incorporated into the specification for these components as a requirement. Testing is being employed in the qualification of these auxiliaries and will be in accordance with the NRC's comments.

6 (5) P.O. 7220-M-14 Auxiliary Feedwater Pumps (Motor Driven)

Based upon vendor submitted sample seismic qualification procedures for the motor driver, the drive will be qualified by analysis and is a rigid component. Therefore, the NRC comments on IEEE-344-1975 do not apply to the motor driven auxiliary feedwater pumps.

(6) P.O. 7220-M-75 Motor Driven Service Water Pumps Although actual qualification information has not been submitted for these motors, it is expected that the motoc qualification will be by analysis and that motor will be rigid. Therefore, the NRC comments A and B do not apply to this order.

Seismic qualification of all future purchase orders which fall under the scops of Regulatory Guide 1.48, and which contain electrical components to which IEEE-344 is applicable till be reviewed against IEEE-344 1975 and the NRC staff comments on IEEE-344 1975.

III B&W Equipment purchased af ter July 1, 1975 In the even't that any NSSS safety-related active components which fall u.: der the scope of Regulatory Guide 1.48 are purchased after

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July 1, 1975, the applicant will demonstrate that such equipment is qualified for operability to at least the same degree proposed for BOP equipment purchased after July 1, 1975.

We further wish to note that a typographical error was made on Table 3 of nur positions on the stress limits for faulted conditions for Class 2 Vessels designed to NC-3200. This error will be corrected in the FSAR to indicate the following for NC-3200 vessels:

Condition Stress Limits Faulted Pmf2.0 Sm (Pm or P1) + Pb 1 2.4 Sm 3

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OCCXET NUM8,1n/330 NRC Popu 195 U.S. NUCLEAR f;GGULATO tY COMMISSION 4*h

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Consumers Power Co.

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cAra RECElvEo Stephen H. Howell l

08/29/77 2 (.zTran ONOTORIZE D PROP lt.PUT PCRM NUMBER OF COPIES RECE!VED GDRIGIN AL M NC LASSIPI E D fQCcPv

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'=cSCalPTION ENCLOSU R E Consists of summary status of Reg.

Guides, 1.20, 1.26, 1.29, 1.46, 1.48, 1.67 & 1.72 in the mechanical engineering Category, and pn providing additional discussion of individual U(,/ f Q:,

Reg. Guides...

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PLANT NAME: MIDLAND UNITS 1 & 2 jcm 08/31/77 i

FOR ACTION /INFORMATION I

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7 INTERNAL DISTRIBUTION f'

REG FILE #

LAINAS

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GA30tILL (2)

P. COLLINS VOLLMER (LTR)

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KREGER MIPC (LTR)

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SIHWEIL PAWLICKI ROSS (LTR)

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1 EXTERNAL DISTRIBUTION CONTROL NUMBER LPDR: A7//21 As/0, j*J/CH 4

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